E.D. Mo. Reverses Social Security Denial Over ALJ’s Copy-Pasted Medical Opinion Analysis

Judge Rodney H. Holmes ruled that the ALJ committed reversible error by using identical, copied-and-pasted language to evaluate medical opinions that received different persuasiveness ratings.

Woehrmann applied for benefits in April 2019, alleging disability since November 2018 due to conditions including major depressive disorder, chronic obstructive pulmonary disease, and residuals from breast cancer treatment.

The ALJ initially denied the claim in November 2023, finding Woehrmann capable of light work with specific mental and physical limitations. The Appeals Council denied review in August 2024, adopting the ALJ’s decision.

The court focused on the ALJ’s evaluation of three mental health opinions and three physical health opinions. State agency consultants and a consultative examiner provided varying assessments of Woehrmann’s functional capacity.

The ALJ found the opinions of state agency consultants Charles Watson, Psy.D., and J. Edd Bucklew, Ph.D., to be "partially persuasive." The ALJ found the opinion of consultative examiner Shea Voelker, Psy.D., to be "not persuasive."

Despite these different conclusions, the ALJ used the exact same text to explain the reasoning for both evaluations. The court noted this "does not convince the Court that meaningful review has taken place."

Under SSA regulations, an ALJ must explain how they considered the supportability and consistency of medical opinions. The court held that merely summarizing medical records without articulating how those records support or contradict the specific opinions is insufficient.

The ALJ’s analysis was further flawed because it evaluated the consistency of the opinions with the ALJ’s already-formulated residual functional capacity, rather than evaluating the opinions independently first.

The court rejected the argument that the error was harmless, noting that the ALJ’s failure to address supportability properly indicated the decision might have differed with a correct analysis.

The case is remanded for the ALJ to fully evaluate and explain the supportability and consistency of all medical opinion evidence in accordance with 20 C.F.R. § 404.1520c.